Michigan v. Doran
Headline: Ruling stops state courts from reexamining another State’s probable-cause finding in extradition, overturning Michigan’s release and making it harder for jailed people to block transfer.
Holding:
- Limits asylum-state courts from reexamining another state's probable-cause finding during extradition.
- Strengthens governors' extradition approvals as evidence, reducing habeas challenges in asylum states.
- Speeds transfers of accused interstate and narrows courtroom hurdles to sending people back.
Summary
Background
A man named Doran was arrested in Michigan after being found with a truck that Arizona authorities said was stolen. Arizona filed a sworn complaint and an Arizona justice of the peace issued an arrest warrant stating there was “reasonable cause.” Arizona’s governor formally requested extradition and Michigan’s governor approved, but the Michigan Supreme Court ordered Doran released after finding the Arizona papers did not show sufficient factual probable cause.
Reasoning
The Court considered whether courts in the asylum State (Michigan) may reexamine a demanding State’s (Arizona’s) judicial finding of probable cause. Relying on the Constitution’s Extradition Clause and federal extradition law, the Court said extradition is meant to be a summary executive process. When a neutral judicial officer in the demanding State has determined probable cause and the governors have acted, asylum-state courts may only verify basic facts on the papers and may not retry the demanding State’s factual probable-cause determination. The Court therefore reversed the Michigan Supreme Court.
Real world impact
People arrested in one State and sought by another will have fewer avenues in the asylum State to challenge extradition by rearguing the factual basis for probable cause. Governors’ approvals and a demanding State judge’s finding will carry strong weight. The Court also left open some Fourth Amendment questions about the precise protections required in extradition proceedings.
Dissents or concurrances
Justice Blackmun, joined by two colleagues, agreed with the result but emphasized the Fourth Amendment should be addressed directly and argued it does apply to extradition and requires a judicial probable-cause check.
Opinions in this case:
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